Advertising Profiling and Third-Party Data Sharing

What it is

T-Mobile may build a profile of your interests based on how you use its services and share that profile with advertising companies, and may share your data with third parties for their own marketing, unless you opt out.

Why it matters (compliance & governance perspective)

This provision authorizes T-Mobile to share your personal data with external advertising partners for commercial purposes beyond your service relationship with T-Mobile, which represents a broader use of consumer data than core service delivery requires.

Consumer impact (what this means for users)

Your network activity, app usage, and demographic information may be used to build advertising profiles and shared with third-party advertising and analytics companies; consumers must actively opt out through the Privacy Dashboard to limit this use.

What you can do

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: This provision engages the CPRA's right to opt out of the sale or sharing of personal information for cross-context behavioral advertising, enforced by the California Privacy Protection Agency. The FTC's commercial surveillance rulemaking and its prior guidance on data brokers and advertising ecosystems are also relevant. Where T-Mobile shares personal data with third parties for those parties' own marketing purposes, this constitutes a 'sale' or 'sharing' under the CPRA's broad definitions, triggering opt-out obligations. The FTC Act's Section 5 applies to any deceptive representations about the scope of advertising data sharing. GOVERNANCE EXPOSURE: High. The assertion that T-Mobile may share consumer data with third parties for those parties' own marketing purposes is among the broadest data sharing claims in this policy and directly implicates CPRA opt-out rights and FTC commercial surveillance concerns. The adequacy of the opt-out mechanism, including whether it is sufficiently prominent and whether opt-outs are honored in practice across all sharing relationships, is a material compliance question. JURISDICTION FLAGS: California residents have a legal right to opt out of this data sharing under the CPRA, and this right is enforceable against T-Mobile. Other states with comprehensive privacy laws including Virginia, Colorado, and Connecticut may provide similar opt-out rights. The specific list of advertising partners and analytics providers with whom data is shared may trigger additional disclosure obligations under CPRA's right-to-know framework. CONTRACT AND VENDOR IMPLICATIONS: Enterprise procurement teams should assess whether T-Mobile's advertising data sharing practices are compatible with their own employee privacy commitments and with any client-facing data processing agreements that restrict third-party sharing. Business accounts should inquire whether employee device data flows are segregated from consumer advertising data pipelines. COMPLIANCE CONSIDERATIONS: Legal teams should audit the current list of third-party advertising and analytics partners to assess whether data sharing agreements satisfy applicable legal requirements including standard contractual terms required by the CPRA. The Privacy Dashboard opt-out mechanism should be tested to confirm it is functional, clearly labeled, and honors opt-out elections across all sharing relationships. Any future changes to the advertising partner list should trigger re-assessment of disclosure adequacy.

Applicable agencies

Applicable regulations

Provision details

Other risks in this policy

• Precise Geolocation Data Collection and Sharing high
• CPNI Use for T-Mobile Marketing medium
• California Consumer Privacy Rights medium
• Data Retention medium
• Data Security and Breach Notification high
• Children's Privacy and COPPA medium

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